Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
A Government company wholly controlled by the State Government through the Governor, with power to appoint and remove directors, was treated as eligible for exemption under section 10(26B) on the basis of its incorporation documents and memorandum and articles of association. The Tribunal followed the co-ordinate bench view in the assessee's own case and accepted that the company was established by the State, so its income was exempt. As the Revenue did not dispute the foundational facts and only raised res judicata, the Tribunal found no error in deleting the additions as non-taxable and upheld the exemption.
A Government company wholly controlled by the State Government through the Governor, with power to appoint and remove directors, was treated as eligible for exemption under section 10(26B) on the basis of its incorporation documents and memorandum and articles of association. The Tribunal followed the co-ordinate bench view in the assessee's own case and accepted that the company was established by the State, so its income was exempt. As the Revenue did not dispute the foundational facts and only raised res judicata, the Tribunal found no error in deleting the additions as non-taxable and upheld the exemption.
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